Below is a copy of the comment that UPOM submitted for the BLM RMP on Sage Grouse protection and management:

The United Property Owners of Montana, which represents over three million acres of privately-owned land in Montana, encourage you to accept the following comments and consider extending the period for public comment in regards to the proposed BLM RMP and the corresponding DEIS.

Despite the attempts of many of our members to discern the exact impact that the BLM RMP would have regarding their individual land holdings, they have found that the amount of information provided by the BLM in regards to the specific areas affected and the extent to which those areas are affected is severely lacking. The current plan omits essential details that would enable the public to substantively analyze and comment on the proposal being made.

Upon inspection of the maps the BLM provided of the areas impacted by the plan we found that the majority of the roads and areas indicated on the map lack specific locations—or, in some cases, anything that made them even remotely distinguishable from one another. Knowing exactly what areas are affected and how they are affected are perhaps the most important pieces of information that individuals have in order to assess the proposal and comment on it. By not adequately providing this information, the BLM has exhibited gross negligence in how they have conducted their meager efforts to inform Montanan’s and solicit public comment in regards to the BLM RMP. This could in part be remedied by an extension of the comment period and with a more effective distribution of accurate information regarding the geographic areas that will be affected by this proposal.

As it stands, the BLM RMP has not adequately followed standard CEQ procedures for gathering reliable data and has instead relied on incorrect “assumptions, estimates, and predictions” (Pages 4-397 through 4-418). What’s more, the DEIS has failed to adequately represent the economic impact of the BLM RMP on small towns, local businesses, farmers and ranchers, and private property owners in general. The DEIS prematurely assumes that there will be very little economic impact without even conducting a thorough analysis of the impacts that would result from the implementation

It’s nonsensical for BLM to assume that they can assess the impact of this proposal when then the public at large and those affected by this proposal are effectively being deprived of their right to have input into this vital process. The BLM needs to not only reconsider the accuracy of the current data that they are using, upon which the DEIS is being based, but need to provide further information (road names, trail numbers, coordinates, etc.) as to the specifics of how the BLM RMP would change the current circumstances relating to the use of land, transportation, and recreational access routes.

The BLM RMP has the potential to severely limit all land use within the area that the plan encompasses—and yet BLM is expecting the landowners, recreationalists, and business owners that would be impacted to shoulder the economic burden associated with this plan, despite it’s clear lack of effectiveness in achieving its purported goal.

If the intent of the BLM is to protect Sage Grouse populations, then the agency should take into consideration the root cause of Sage Grouse deaths, which is not the increased development of natural resources, use of property, agriculture, use of recreational roads, or motorized vehicle access. Rather, the factors responsible for a Sage Grouse population decline are natural ones—primarily predators and changes weather patterns.

We encourage the BLM to include the economic impacts the proposed RMP would have on small towns, local businesses, agriculture, and property values in the DEIS. We also urge the BLM to include an analysis of the impacts the RMP would have on private property rights, land values, land access, agricultural permitting, surface use and any other use of private property that may be inhibited as a result of this the proposed RMP. The above listed analysis should also include the impacts of lost agricultural production as a result of the RMP, increases in unemployment rates, decreases in private sector job opportunities, and the negative impacts of additional restrictions on energy and natural resource development efforts. BLM should also delineate the process whereby property owners will be provided just compensation for any of their property that is taken as a result of this proposal, as required by the Fifth Amendment to the Constitution, as well as estimate the amount of compensation that could be owed.

We sincerely hope you will consider an extension of the comment period, as well as the distribution of additional information pertaining to the details of this proposal.